What triggers child resistance
Updated
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The structure of the rule
16 CFR 1700.14(a) lists substances the Commission has determined are hazardous to children by reason of their packaging, and for each one gives a threshold and a cross-reference to the standard in 1700.15. There is no fragrance category on the list, which is exactly why makers in this trade miss it.
Methyl salicylate, over 5 percent by weight
Liquid preparations above that figure, other than those in pressurized spray containers, must be in special packaging. Wintergreen and sweet birch oils are predominantly methyl salicylate, so a blend using either as a main note can clear 5 percent without anybody intending it.
Hydrocarbons, 10 percent or more
Paragraphs (a)(31) and (a)(32) catch nonemulsion liquid household products containing 10 percent or more hydrocarbons by weight with a viscosity under 100 SUS at 100 F. One applies to hazardous substances under the FHSA, the other to drugs and cosmetics under the FDCA.
What counts as a hydrocarbon
The rule defines it narrowly: substances consisting solely of carbon and hydrogen. For products with several, the percentage is the sum of the individual components by weight. Isoparaffins and mineral oil count; a glycol, which carries oxygen, does not.
Lamp and lantern fuel has its own paragraph
Paragraph (a)(7) covers prepackaged liquid kindling and illuminating preparations, naming fuel for decorative lanterns, at 10 percent or more petroleum distillates with a viscosity under 100 SUS. If you sell anything meant to be burned, read that one directly.
Do the arithmetic before the artwork
Every one of these is a number you can compute from your own formula sheet in an afternoon. Discovering it after bottles, closures and labels are bought is the expensive way to learn the same fact.
Read the paragraph that applies to you
The list runs to 33 entries and each has its own threshold, its own exemptions and its own cross-reference into the standard. Summaries, this one included, exist to tell you which paragraph to open rather than to stand in for having opened it.